Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Validity of reopening of assessment u/s 147 - it cannot be stated that the petitioner was not aware of the reasons for reopening of the assessment. The petitioner has replied to the proceedings initiated under Section 148 of the Income Tax Act, 1961. The petitioner has not asked for a speaking order - Having given up the right to ask for a speaking order, the petitioner cannot now turn around and question the Impugned Order by stating that it has been passed over-looking the safeguard prescribed in the case of GKN Drive Shafts (India) Limited. Further, case also does not warrant a speaking order in terms of the aforesaid decision of the Court. - HC
Validity of reopening of assessment u/s 147 - it cannot be stated that the petitioner was not aware of the reasons for reopening of the assessment. The petitioner has replied to the proceedings initiated under Section 148 of the Income Tax Act, 1961. The petitioner has not asked for a speaking order - Having given up the right to ask for a speaking order, the petitioner cannot now turn around and question the Impugned Order by stating that it has been passed over-looking the safeguard prescribed in the case of GKN Drive Shafts (India) Limited. Further, case also does not warrant a speaking order in terms of the aforesaid decision of the Court. - HC
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